Finding Text
Finding 2024-001: Written Procurement Policy
This finding impacts the procurement and suspension and debarment compliance requirement for the major program, Assistance Listing Number 10.555 National School Lunch Program (Child Nutrition Cluster) funded by the Commonwealth of Massachusetts Department of Elementary and Secondary Education (DESE).
Criteria: According to 2 CFR sections 200.318 through 200.326., recipients of federal awards must adhere to specific procurement standards, including maintaining documented procurement procedures, ensuring oversight of contractors, and avoiding conflicts of interest.
Condition: During the fiscal year 2024 compliance testing of Nurtury’s Nutrition program, it was noted that Nurtury’s procurement policy did not align with the Uniform Guidance procurement requirements.
Context: Compliance with the Uniform Guidance.
Cause: Nurtury has not updated its procurement policy to reflect the current Uniform Guidance requirements.
Effect: Failure to update the procurement policy in accordance with Uniform Guidance could result in questioned costs and findings related to Nurtury’s Federal programs.
Was the finding a repeat of a finding in the immediate prior year?: No
Questioned Costs: None
Recommendation: Nurtury should revise its procurement policy to comply with Uniform Guidance requirements. Nurtury should implement procedures to periodically search for suspended or debarred vendors on Sam.gov to ensure compliance with federal guidelines.
Management Response: Nurtury is in the process of updating its procurement policy to conform with Uniform Guidance procurement requirements. Management has confirmed in Sam.gov that none of their current vendors are suspended or debarred. The updated policy in development will ensure procedures to regularly search for suspended or debarred vendors on Sam.gov.